March 10, 2022
In light of the government sanctions against Russia, the Responsible Minerals Initiative (RMI) is consulting with legal counsel and evaluating impacts on its audit programs. The list of the RMI smelters and refiners participating in the Responsible Minerals Assurance Process (RMAP) audit program, including those based in Russia, is available here; this list has been updated to reflect the LBMA's Good Delivery List suspensions for six Russia-based gold refiners which had been cross-recognized by the RMI.
As part of auditee onboarding, the RMI collects information on auditees’ company structures, direct and beneficial ownership. The RMI is also now asking all Russia-based auditees participating in the RMI RMAP to provide current information on company structure, direct and beneficial ownership to verify any potential impacts of the new sanctions on conformant status or eligibility.
Furthermore, the RMAP requires all auditees to conduct know-your-customer (KYC) and sanctions checks on their suppliers, and not meeting those requirements or completing required corrective actions will result in removal from the RMI’s public Conformant list.
The RMI will continue to monitor this situation as it evolves and will communicate with its members, auditees, and auditors about any developments impacting the RMI’s operations and audit programs. The RMI recommends that companies consult with their legal counsel for the direct impacts on their operations and supply chains.
In addition, given the context, members can also prioritize applying enhanced supply chain due diligence in line with international standards to ensure they are:
- Protecting physical safety and mental well-being of your employees to the extent possible
- Complying with international sanctions
- Not causing or, through their business relationships, contributing to adverse human rights impacts
- Following internationally accepted principles for responsible disengagement to mitigate unintended consequences, if suspending operations temporarily or permanently
- Participating in remediation where appropriate, including where directly linked to adverse human rights impact through business relationships
The UN Guiding Principles on Business and Human Rights, OECD Due Diligence Guidance for Responsible Business Conduct and OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provide the foundational principles and expectations for member review.
